Liberty and justice for all United States persons abroad

The Isaac Brock Society

Men are not prisoners of fate, but only prisoners of their mind – RIP @Marciovp – @ADCSovereignty

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cross-posted from ADCSovereignty WordPress Blog

This is a post that I began to write on August 20, 2015. The post was in response to the death of Dr. Marcio Pinheiro.  Trish Moon wrote a tribute to Dr. Pinheiro at the Isaacbrocksociety. I urge you to read both the post and the comments to that post.

Dr. Pinheiro was a “naturalized U.S. citizen” who was living in Brazil. There is NO DOUBT that the attack on Americans abroad, which was orchestrated and prosecuted by the Obama administration, made the last years of his life a “living hell”. Marcio Pinheiro was a victim of Obama administration policies that began in 2009. These policies  shaped the finals years of Marcio’s life. For those who are NOT aware of the origins of the fear and anger experienced by Americans abroad, I invite you to read: “Never Forget What Happened in 2011” and the comments (also by Trish Moon).

I am motivated to finish this “dormant” post, by Trish Moon’s superb “It’s NOT the Taxes, it’s the Effect on Real Lives, Stupid” post which she published on December 31, 2015. That post is destined to be become a “classic”. The main purpose of the post is captured in the language:

By governments not addressing what the tax laws actually mean–in the life experience of those affected (including their immediate “alien” families) they are disabling a whole class of citizens from participation in the normal opportunities available to other citizens, based upon nothing less than a U.S. claim of ownership; due in most cases merely for having been born there.

This is what we have somehow failed to communicate clearly enough. Perhaps it will take a couple of more years before the damage begins to be more obvious.

The story of Dr. Pinheiro is NOT a story of taxes. It’s the story of the extra-terroritorial application of U.S. law. It’s the story of how the provisions of those extra-territorial laws destroy the lives of those who reside outside the U.S. and are deemed by the U.S. to be “U.S. Persons” (primarily based on place of birth).  It is also a story of the role that the media, the tax compliance community, and now other governments (via FATCA IGAs) play  in the enforcement of U.S. law on the  residents and citizens of other nations. Remember that Dr. Pinheiro was a citizen of Brazil living in Brazil. Remember also that the vast majority of people affected by FATCA and the application of U.S. tax laws in Canada, are Canadian citizens living in Canada.

There is no evidence that Dr. Pinheiro owed the U.S. Government any taxes. The evidence is that his concern was his  failure to file the FBAR (“Foreign Bank Account Report”). He was required to file the FBAR to disclose to the U.S. Government the bank accounts that he used to manage his life in Brazil. The belief prior to 2015 was that: the failure to file the FBAR could have subjected him to penalties that would exceed 300% of the value of the bank account. (The IRS has only recently clarified its position on this.) Think of it: a man’s life destroyed because of fear of penalties for having not disclosed his local bank accounts to the U.S. Government (when nobody even knew of the patently absurd requirement to do so). Are Homelanders required to disclose their local bank accounts to the U.S. Government? (Those who are “Looking for Mr. FBAR should read here and here.)

Remember this. Dr. Pinheiro lived in a state of terror NOT because he didn’t want to comply with U.S. laws. He lived in a state of terror because he did want to comply with U.S. laws. Hmmm….

That’s worth repeating. This time I think I will bold it:

Remember this. Dr. Pinheiro lived in a state of terror NOT because he didn’t want to comply with U.S. laws. He lived in a state of terror because he did want to comply with U.S. laws. Hmmm….

Now continuing where I left off in August of 2015.
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As goes the history of taxation, so goes the history of civilizations and that’s a #FATCA

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This post is largely based on an earlier post at the RenounceUScitizenship blog.

I accidentally came across an incredible book by Charles Adams called:

For Good and Evil – The Impact of Taxes on the Course of Civilization.

One review is here.

This is a tremendous book. I specifically recommend Chapter 37 “Learning From The Past”. I remain convinced that the single biggest threat to the United States (and possibly the rest of the world) is the complexity of the Internal Revenue Code of the United States. Mr. Adams is a brilliant tax historian who demonstrates how the history of civilizations may be understood by studying the history of their tax policies. At the present time the United States is under direct attack. The attack is NOT coming from outside the United States (no it’s not from Americans abroad). The attack is coming from the lethal combination of a corrupt Congress that does evil by tinkering with the Internal Revenue Code.

This is not the first time that I have posted about Charles Adams at the Isaac Brock Society. In an earlier post, I introduced Mr. Adams as follows:

 

Here are some of what Charles Adams considers to be the 27 lessons from the history of taxation (page 452 of the first edition of his book: “For Good and Evil – The Impact of Taxes On The Course of Civilization“):

11. If liberty is to be defended with success against the dominance of the state, then financial privacy must be preserved. Banking privacy is one the cornerstones of liberty, having its roots in the principle of early English Law that a man’s castle (primarily his treasury) is beyond the surveillance of the king.

24. Taxes that are not apportioned among all taxpayers with impartiality and fairness lose all force of moral obligation.

Mr. Adams was writing in 1993 before FATCA and the “FBAR Fundraiser“.

In any event, I am thrilled to see that the Mises Institute hosted Charles Adams for a week of seminars (which are based on the book).

Better yet, the seminars are (the wonders of technology) available below on YouTube. I haven’t listened to them yet. But, if they are like the book. Mr. Adams will give you a model to understand tax policy and the impact that it is sure to have on the future of the United States.

Incredible stuff! Highly recommend (and no I have never met Mr. Adams.) I hope that you take the time to listen to some of the videos.

 

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It’s NOT the Taxes, it’s the Effect on Real Lives, Stupid

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Opened my email today to see a one from Kat Jennings CEO at Tax Connections and noticed the headline:

“Check out the top 20 Tax Blogs in 2015! “During 2015 readers of Tax Connections Worldwide Tax Blogs arrived from more than 200 countries and spent an average of 12:45 during each visit. These are mighty numbers…”

Interestingly, of the 20, at least 10 of them, dealt with issues that affect us.

Delighted to notice:

at #2) How To Live Outside The United States In An FBAR And FATCA World by John Richardson

at #4) Fighting FATCA “Tyranny” by Lynne Swanson (will include in a future post….)

I read John’s post again. These excerpts stick in my mind:

Your problem IS actually attempting to live as a “tax compliant” U.S. citizen outside the United States. It’s easy to live as a U.S. citizen abroad who is NOT “U.S. tax compliant”. What is very difficult is to live as a “U.S. citizen abroad” who IS “U.S. tax compliant”.

U.S. citizens, regardless of where they live in the world, are subject to exactly the same provisions of the Internal Revenue Code. At first blush you might think this is fair. No.

The problem is that the U.S. tax code imposes punitive taxes and reporting requirements on “all things foreign to the U.S.”. As a U.S. citizen abroad, your life is completely “foreign to the U.S.”. Therefore, your life will be subject to punitive taxes and reporting requirements. You will learn this as you become more and more U.S. tax compliant.

 
This situation is not about tax.
Those drawn up in this mess do not have tax problems.
They have compliance problems. Once filed, THEN they WILL have tax problems.
 
So what say the accountants and lawyers. You won’t owe any income tax. Unlikely to receive penalties, fines, interest. So what’s the big deal?
 
By governments not addressing what the tax laws actually mean–in the life experience of those affected (including their immediate “alien” families) they are disabling a whole class of citizens from participation in the normal opportunities available to other citizens, based upon nothing less than a U.S. claim of ownership; due in most cases merely for having been born there.
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Bopp FATCA Case Update: Plaintiff’s Opposition to Government’s Motion to Dismiss

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This just out from Republicans Overseas:

Yesterday [29.12.2015] Mr. Bopp filed his 36-page Plaintiffs’ Memorandum in Opposition to Defendants’ Motion to Dismiss in the US District Court for the Southern District of Ohio. DOJ lawyers asked Judge Rose to dismiss our lawsuit.

Mr. Bopp argued the lawsuit is justiciable for three reasons: plaintiffs have standing, the Anti-Injunction Act does not bar plaintiffs’ claims, and plaintiffs Eight Amendment claims are ripe for adjudication.

Mr. Bopp further argued plaintiffs should be granted relief requested based on their claims for four reasons: the IGAs are unconstitutional sole executive agreements, reporting requirements violate equal protection for Americans living abroad, the challenged penalties violate the Excessive Fines Clause, and reporting requirements violate the Fourth Amendment.

Now we are waiting for Judge Rose’s ruling not only on this matter, but also on Plaintiffs’ Motion for Leave Amend Complaint. We expect both rulings will be handed down in 2016. This only means our fight to defend 8.7 million overseas Americans’ constitutional rights continues. Happy New Year!

Link to Republicans Overseas Facebook Post (thanks to Keith Redmond): Mr. Bopp filed his 36-page Plaintiffs’ Memorandum in Opposition to Defendants’ Motion to Dismiss in the US District Court for the Southern District of Ohio

The entire pleading may be downloaded here: Plaintiffs’ Memorandum in Opposition to Defendants’ Motion to Dismiss

Related IBS posts about the “Bopp” lawsuit:
Judge Rose denies plaintiffs application for injunction in the Bopp FATCA Legal Action Lawsuit.

Finally the Bopp suit has arrived

And as a reminder, link to the FATCA Legal Action site if you would like more information or to donate towards the effort:
https://fatcalegalaction.com/

The #FATCA is that: The Internal Revenue Code is the greatest weapon on the battlefield of class warfare

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Introduction: complexity = your best tax planning opportunity …

In the post: “While some Homelanders have a private tax system – USA imposes FATCA and CookvTait on #Americansabroad” I argued that: the more complex the system, the less the possibility of understanding the rules. The less the rules can be understood, the more the rules can be exploited. The super rich are able to pay in order to exploit the complexity of the rules to ensure that they pay a lower percentage of tax. This is the true cost of the complexity of the Internal Revenue Code. It is also why the biggest threat to America is not from outside the borders. The biggest threat to America is a Congress that uses the Internal Revenue Code to do political favors for favored individuals. Remember the story of Mr. Stack (and I don’t mean the Mr. Stack of “It’s a myth fame)“.

Wilton Jere Tidwell commented that:

The Marxist Income Tax lends itself to evasion unless you are honest and then it is so complicated that nobody gets it right. There are more words in the tax code than in the Christian Bible and the code is harder to read and understand.

We really need to go back to the founders idea of a sales Tax on all new goods sold, that way even the pimps and others criminals would pay as they spend and the overseas citizens could live their lives without fear of the Jackbooted IRS. The latest is they port of entry officials will check to see if you are tax compliant and confiscate your passport or revocation if you aren’t compliant.

I am a proponent of the FairTax and until we do it there will just be more hardship and strife.
Congress wants the issue and also wants the campaign funds they get to give special tax breaks to the people with money to contribute to their funds.

As goes the complexity of the Internal Revenue Code, so goes the opportunity to exploit that code for the payment of less tax.
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While some Homelanders have a private tax system – USA imposes FATCA and CookvTait on #Americansabroad

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Cross posted from the RenouceUScitizenship blog.

A FATCA fairy tale …

A “Bed Time story” explaining why FATCA does not matter in the least for those it was supposedly intended to target!

Once upon a time in America –
There were some homelanders who didn’t pay their fair share!

Most of the taxes were paid by higher income earning homelanders!

Unless you were a “super wealthy” homelander in which case you could create your own special tax system and pay the lowest taxes of all!

Which created many revenue shortfalls.  So Congress passed laws to benefit Homelanders and forced Americans abroad to pay for those benefits, by including “Revenue Offsets” in those laws.



The President asked:

“Mirror, Mirror on the wall.  What’s the greatest “Revenue Offset” of them all?”

The Face In The Mirror Answered:
The greatest “Revenue Offset of Them All” is FATCA. FATCA is the “gift that just keeps on giving”.

And the President signed FATCA and  sent the IRS to hunt Americans abroad with the greatest “Revenue Offset Provision Of Them All”

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The comments of @submergingmkt James Henry appear to assume that the #CookvTait Principle of extra-territorial taxation is correct

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Introduction

 

This is cross posted from the RenouceUSCitizenship blog. I find it fascinating that many U.S. politicians and observers of U.S. tax policy are upset that it is possible to comply with U.S. tax law and to avoid paying taxes to the United States. Isn’t this an admission that tax reform in the United States is required? Shouldn’t these people be expressing their rage at Congress? After all, as Tim Cook says:

“It’s a tax code. It should have been changed years ago.”

Yet, (for reasons that are inexplicable to me) these politicians vent their rage at the companies. The tax code encourages U.S. persons (including corporations) to leave the United States. Instead of changing the tax laws, people like Hilary Clinton, Carl Levin, Barack Obama and his Motley Crew of Democrats want to punish them for leaving. Do they believe that “U.S. persons” are owned by the U.S. Government? Is that the problem? U.S. persons who renounce their citizenship (whether Green Card abandonment, corporate inversions, or straight renunciations) are somehow escaping their rightful owners? Are these people for real?

The current S. 877A Exit Tax rules were originally proposed by President Bill Clinton in 1996. Hilary Clinton is now proposing Exit Taxes on U.S. Corporations.

Perhaps “U.S. Exit Taxes” should renamed: U.S. “Clinton Taxes”. In any event …

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#CookvTait principle has created problems for Apple and has created advantages for non-US persons and corporations

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The U.S. tax code discriminates against ALL THINGS AMERICAN. Both Apple and Americans abroad suffer from the archaic U.S. tax code. The following article from the RenounceUScitizenship blog canvasses this issue.

Introduction …

The U.S. tax system is premised on the assumption that it can levy taxes on economic activity in other nations. This simple premise applies to both corporations and to individuals.

In the case of individuals: The taxation of economic activity in other nations takes place at the time that the money is earned.

In the case of corporations: The taxation of the economic activity, the taxation takes place when the money is returned to America.

In any case, the United States discriminates very strongly and punitively against all things American. The views of Apple CEO Tim Cook has some interesting comments on this issue.

Apple CEO Tim Cook interviewed on 60 Minutes 2015 …

”This is a tax code, Charlie, that was made for the industrial age, not the digital age,” he said. “It’s backwards. It’s awful for America. It should have been fixed many years ago. It’s past time to get it done.”

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Passport Tort

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This posting is dedicated to Meunier.

 
Caveat:  only a lawyer can or should attempt to read written law. (You can pay lawyers, and pay them exorbitantly — with no guarantees that they can read the stuff either.)

Even so, an extraterritorial U.S. person who holds only a U.S. passport may want to take a glance at the recent passport-related legislation glommed into the FAST Act.

The Fixing America’s Surface Transportation Act can be found at

        https://www.congress.gov/114/bills/hr22/BILLS-114hr22enr.pdf

On pages 418-422 is found

        Title XXXII–OFFSETS
        Subtitle A–Tax Provisions

which adds to Internal Revenue Code “the following new section:”

        SEC. 7345. REVOCATION OR DENIAL OF PASSPORT IN CASE OF
        CERTAIN TAX DELINQUENCIES.

The not-comforting language in these five pages includes this zinger:

The taxpayer may bring a civil action against the United States in a district court of the United States or the Tax Court to determine whether the certification was erroneous or whether the Commissioner has failed to reverse the certification.

This seems to translate as — “You think the U.S. has made a mistake? O.K. Up to you and your lawyer to sue the United States. And good luck to you.”

The tired cliché “Timing is everything” may liven up with entirely new meanings for a person who finds themselves assessed and then either has notice of lien filed against them with “administrative rights” OR faces levy “pursuant to section 6331.”

So what is that bit after the little word “or”? It seems to be this:

        26 U.S. Code § 6331 – Levy and distraint
        https://www.law.cornell.edu/uscode/text/26/6331

This section starts off with some viciously tight timelining:

If any person liable to pay any tax neglects or refuses to pay the same within 10 days after notice and demand, it shall be lawful for the Secretary to collect such tax (and such further sum as shall be sufficient to cover the expenses of the levy) by levy upon all property and rights to property …

Apart from the clear presence of time windows whose business is inexorable closure (whatever the specified periods may amount to in the only-for-lawyers details), some more accessible news (p. 421-422) falls under the heading

        WITHOUT SOCIAL SECURITY ACCOUNT NUMBER

and provides for the denial of passport to anyone (i) not providing a number, or (ii) providing “an incorrect or invalid social security number willfully, intentionally, negligently, or recklessly.”

That memorable string of adverbs should cover just about anything?

When all is said and done, though, only a lawyer can or should attempt to read written law.

But sometimes curiosity leads into doing scary things. Especially scary for the extraterritorial U.S. person without alternative passport.

Yours truly, a fearless explorer, a survivor of many shipwrecks — never through airlift because neither a bird (condor, ostrich, whatever) nor a U.S. person who can count on that famous benefit of worldwide extraction from dire situations.

Oops, forgot, ostriches can’t fly anyway. Still, they are feathered bipeds. Feathered without tar, by the way.
 

Fatca Forum Exactly 3 Years Ago Today! How Far We Have Come!!

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UPDATED
The video links are hopefully fixed. I neglected to acknowledge that the transcripts were made by pacifica and calgary411. Any emphases are mine.

 


 

I had intended to write something for Brock’s 4th birthday (December 10) but when I got up and looked at the calendar I noticed I had missed it. But then I realized, today was the 15th and that the FATCA Forum was exactly 3 years ago today. I actually feel as if it were 10 years ago, probably because so much has happened since then and it has been so intense.

Brock was certainly the start of our section of the expat movement. Absolutely no doubt about it. But the FATCA Forum was the beginning of something else equally important – Brockers coming together and becoming active in other ways. I definitely think without the Forum, things would not have taken shape in the way they have.

Likely a lot of you have never seen the videos/read the transcripts of that day. Some people seemed to think that since there weren’t hundreds of people there, it wasn’t effective. But they couldn’t have been more wrong.

Technically, if I remember (and someone please correct me if they know otherwise), the meeting was sponsored by the Progressive Canadian Party, headed by the Hon. Sinclair Stevens. I remember being quite impressed by him; such a gentleman but no-nonsense about the shenanigans that had taken place when the Conservative Party voted to dissolve the party and merge with the Canadian Alliance to form the modern-day Conservative Party of Canada. I had absolutely no idea what he was talking about. But then he started to talk about the Charter. Up to that point, I don’t recall focusing on the idea that Canada would be/could be involved in helping us out of the miserable situation we all found ourselves in which at that point was mostly about FBAR and renunciation. When he said the Charter didn’t apply just to citizens, it included permanent residents, visitors, in fact anyone who happened to be in Canada, he planted the seed for the CDN lawsuit (at least in my mind).
 


 

…. in the sense that I think it’s very appropriate today. Canada needs representation at the national level.
And what you are considering today – and I’m looking forward to some of the experts that are here to discuss it is the fact that a foreign nation is attempting to levy taxes against people who are still technically citizens of the United States – and there are over a million of them in Canada – and we say that’s just wrong. It’s just inherently wrong not to acknowledge the sovereignty in this case of Canada.

And to that extent there will be three headings that you will be told about today. But the heading that I’m most interested in is the Canadian Charter of Rights and Freedoms. I was in Parliament when that was passed in 1982. I remember the debate. I remember the significance that was felt, not only in Parliament but throughout the country, that we were getting our own Charter, a Charter that would identify what is uniquely the Canadian rights and freedoms.

Now, the reason it’s relevant to today, as I’ve indicated what we’re living with is this threat from the United States, who wish to become extra-territorial in the sense of tax collection – I think it’s interesting to bear in mind some of the wording of the Charter of Rights and Freedoms.

In order that there is no doubt that a permanent resident of Canada has a say and it must be protected, I would refer you to s. 6 of the text of the Canadian Charter of Rights and Freedoms. It says:

“Every citizen of Canada and every person who has the status of a permanent resident of Canada has the right” and that section deals with certain things.

But the most significant section of the Charter is s. 15(1) – and put yourself in the context when I say “individual,” put yourself in the context of a US citizen, according to the Americans, being referred to. That section says:

“Every individual is equal before and under the law and has the right to the equal protection and equal benefit of the law without discrimination and in particular without discrimination based on race, national or ethnic origin, colour, religion, sex, age or mental or physical disability.”

That catches the so-called US citizen. Certainly if he’s been here longer than six months, he’s a permanent resident. And this Charter and coming out of today, if you agree, we will be making a representation first to Finance in Ottawa, who have requested comments on this subject. We will be making a representation among other things pointing to the need to obey the Charter of Rights that is thirty years old in Canada.

I thank you for coming. I hope to hear your input as we go ahead. But by all means, you are doing a great service for Canada and the citizens and permanent residents of Canada.

Thank you very much.

 
John Richardson was one of the first people to make us aware of the fact that FATCA et al, was NOT about taxes. People often miss his point when he says “You don’t have a TAX problem, you have a COMPLIANCE problem. They haven’t filed their taxes, how is it they don’t have a tax problem? They don’t understand what he means when he says it’s a myth that Americans abroad won’t owe any taxes. Of course what he means is that once you have dealt with the compliance problem by filing, THEN you will begin to have tax problems. He was the first person I can remember who made us understand that it wasn’t about owing income tax; of course, many do not due to the FEIE, FTC etc. I believe nobody understands better than he, where we WILL owe:

  • when we sell our homes
  • when we invest in tax-deferred savings accounts that the US will not recognize
  • when we invest in non-US mutual funds
  • when we file a US tax return as MFS (incurring AMT & Obamacare tax)

Understanding tax is not the point, it is understanding how it affects peoples’ lives. And one of the reasons he gets this better than anyone else could not possibly be demonstrated better than the following explanation:
 

 

Now the US is a country that really doesn’t like anything that they call ‘foreign’. In fact, if you were actually to look at the Internal Revenue Code in theUS, you would see that the word ‘foreign’ wherever the word ‘foreign’ is, the word ‘penalty’ is sure to follow. Now what this means is that a number of day-to-day activities that people in Canada and other countries engage in, which by the way are heavily promoted by government policy, things as unimportant in life as retirement planning for example, are in fact subject to US tax laws and are taxed in very, are not recognized, as tax-saving vehicles. Now I’m going to give you one example. I could give you more but I just want to give you one example to demonstrate the point. As you know, the Government of Canada in 2009 introduced something called a TFSA, Tax-Free Savings Account. How many have heard of that? And, it is, I think this is very important to understand that this is part of what is considered to be desirable domestic Canadian policy to assist and encourage people to save for retirement. Agreed?

Well, let me tell you what that is from the point of the United States Government. First of all, it is not recognized as anything, but remember that US Persons are required to file tax returns accordingly to exactly the same laws that people in the United States are and because there are no TF(S)A’s in the US, therefore there are no TFSA’s anywhere in the world, but under US law for example, these are considered to be a ‘foreign trust’. Now, so what you ask? Well, in theUStax system on the one hand there’s the issue of how much tax is owing. But, there’s another dimension to it, which is used which I think also, I suspect, to raise revenue and this has to do with the filing of information returns.

OK? So, in other words, it’s OK to have a foreign trust, but what’s not OK is to not report it to the IRS. Well, you might think, OK, so what, so let’s, we’ll call them up and drop them a line. Not so simple. Very complicated reporting requirements, very complicated forms. For those of you who areUStax geeks, you might recognize the Form 3520 for those who have been thinking about this. You say so what, give me the form, I’ll fill it out. You will not be able to fill out this form without professional help, totalling thousands of dollars, if you can even find that kind of professional help in this country. And, the penalty for non-willful, $10,000. How many think that’s absolutely outrageous? You do? Well, you’re not going to believe what I’m about to tell you next then. Because, it’s a foreign trust and the one thing theUStax system is based on a system of complete distrust, they want verification from what is called the Trustee. Now in people talk that means if you have a TFSA at, say, the Toronto Dominion Bank, the Toronto Dominion Bank would be the Trustee and the Trustee, under US (imagine this, OK), under US law, the Trustee, the TD Bank, is required to file with the IRS a form which essentially duplicates your form to essentially just validate that in fact you’re telling them the truth. You think the TD Bank is going to do that; how many imagine they’re going to do that? No, they’re not.

Well, the problem is this. Two problems. The first is, your tax return if you’re living in the USis due April 15th. For people outside the US, it’s June 15th and you can get an extension until October (OK, if you don’t owe them any money. We’ll get to that – I see you’ve had some problems here – I’ll be interested in hearing later.). If this form is not filed by March 15th, which by the way is well before the due date of your tax return, then you, not the TD Bank, you are subject to another $10,000 penalty. OK? Now, I’m going to just continue the discussion of the forms and the penalties in a specific way, but what you need to understand, and for the purpose of this whole discussion today, is that when we’re dealing with theUS tax system, we have taxes, which you understand. I mean there’s nobody inCanada who could not understand taxes. How many think they are high? Oh, you don’t? OK, but what you don’t understand and what’s left out of this discussion is the information returns which are actually the bigger problem, a) because nobody knows about them and b) because I guarantee you, and I’m going to stand by this word (I would rarely use the word, guarantee) that nobody except a person who does not own anything except the shirt on their back could afford to file a US tax return for under about $3,000, and I don’t care who you are. If you have anything, OK, if you have anything, it’s going to be much more and I know somebody personally who filed aUS tax return in 2011 that was almost 200 pages of information returns. Very middle class person as far as I can see unless there’s some stash that he hasn’t told me about, in which case I don’t think he’d be telling to the US government either. But my point is that we are dealing with a tax system of enormous complexity. I’ve heard it referred to when it’s applied to US Persons abroad as simply nothing more than a tax and penalty club.

 
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